United States securities and exchange commission logo
February 5, 2024
Jeffrey Armbrister
Chief Financial Officer
Hamilton Lane Incorporated
110 Washington Street, Suite 1300
Conshohocken, PA 19428
Re: Hamilton Lane
Incorporated
Form 10-K for the
Fiscal Year Ended March 31, 2023
File No. 001-38021
Dear Jeffrey Armbrister:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2023
2. Summary of Significant Accounting Policies
Concentrations of Risk, page 119
1. We note that your
disclosure of revenues by geographic location on page 120 includes
reference to Other
foreign countries in totality. Given your global presence, in future
filings, please revise
your disclosures to clarify whether any revenues attributed to an
individual foreign
country are material, and, if so, to disclose such amounts separately, as
contemplated by ASC
280-10-50-41(a).
Reclassifications, page 120
2. We note your disclosure
that certain prior period amounts have been reclassified to
conform with current
period presentation. Please tell us what prior period amounts and
line items have been
reclassified in these historical financial statements and revise your
disclosures, in future
filings, to provide further clarity on any reclassification changes,
such as the nature,
magnitude and the specific impact on affected line items in the
financial statements.
Refer to ASC 205-10-50-1.
Jeffrey Armbrister
Hamilton Lane Incorporated
February 5, 2024
Page 2
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Cara Lubit at 202-551-5909 or Marc Thomas at 202-551-3452
with any
questions.
FirstName LastNameJeffrey Armbrister Sincerely,
Comapany NameHamilton Lane Incorporated
Division of
Corporation Finance
February 5, 2024 Page 2 Office of Finance
FirstName LastName